Welcome to MetroClick, a website owned and controlled by MetroClick, Inc. (“MetroClick”, “we”, “us”, or “our”). We operate the MetroClick interactive kiosks and platform, which makes sharing content through touch screen interactive devices fun, easy and valuable. We provide this privacy policy to let you know what information we collect, how we use it, share it and protect it.

Scope

This Privacy Policy applies to the website located at www.MetroClick.com (the “Site”), the tools and interactive content made available through the Site and the MetroClick sharing platform, as well as a number of related services (collectively the “Services”).

As a general rule there are two categories of users of the Site and Services: “Publishers” who are operators or publishers of websites and/or interactive kiosk content that make the MetroClick sharing platform available on their website, and “End Users” who are individual visitors of a website and/or interactive kiosk and use the MetroClick platform to share a photo or other data associated with MetroClick interactive touch content. By visiting the Site or using the Services, you are accepting the policies and practices described in this Privacy Policy.

MetroClick complies with the U.S.-EU Safe Harbor Framework and the U.S. Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information (defined below) from European Union member countries. MetroClick has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor.

Advertising Choices
MetroClick, builder and operator of the MetroClick platform, adheres to the policies of several industry groups that focus on effective communication, best practices, and policy review in the field of Online Behavioral Advertising (OBA). These organizations include the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA), and the Interactive Advertising Bureau (IAB). We are compliant with both the NAI and DAA self-regulatory codes.
We believe that delivering targeted and relevant advertising enhances your internet and creative touch content experience. We collect non-personally identifiable information from many of the websites and/or interactive touch screen devices in which an MetroClick Platform is enabled, and use that information to deliver targeted advertising on those websites and/or interactive touch screen devices as well as other websites you may visit. If you prefer that we do not collect Non-Personally Identifiable Information about your website visits for the purpose of delivering targeted advertising, you may opt out.

When you opt out, we will place an opt-out cookie on your user records. The opt-out cookie tells us not to use your information for delivering relevant online and/or direct advertisements. Please note that if you block cookies, our opt-out process may not function properly. Please also note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser or interactive touch screen kiosk, you will need to renew your opt-out choice.

Privacy Practices by User Category:
¥ Privacy Practices for Visitors to the MetroClick Site(s)
¥ Privacy Practices for End Users Who Use the MetroClick Sharing Platform on Publisher Sites
¥ Privacy Practices for End Users Who Download and Use MetroClick Toolbars

Privacy Practices for Visitors to the MetroClick Site
(a) The Information We Gather and How We Use it: The Site is primarily directed to Publishers of interactive content, although we welcome End Users who want to know more about our Services. When you access the Site or Services, we may collect the following information:
¥ Personal Information — We collect Personal Information when you knowingly provide it, including when you register for the Site, provide feedback, or request information. Personal Information is information that may be used to identify or locate an individual, like a person’s full name, postal address, e-mail address, or phone number, as well as other non-public information that is associated with this Personal Information. We use your Personal Information to administer your account and provide you services, to send communications and administrative emails, to respond to your inquiries, and to send marketing and product update messages to those who ask for such messages. Typically, Publishers, rather than End Users visit the Site in order to access and register for the Services.
¥ Non-Personally Identifiable Information — We collect Non-Personally Identifiable Information automatically when you visit our Site. Non-Personally Identifiable Information is information that is not used nor intended to be used to personally identify an individual and is not associated with nor linked to Personal Information. This Non-Personally Identifiable Information we collect via the Site includes your Internet Protocol address, browser type, browser language, the date and time of your request, and the web page you have visited immediately prior to visiting the Site.
¥ Cookies — We use Cookies on this Site. “Cookies” are small pieces of information that a website sends to your computer’s web browser while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed or blocked by following the help file directions in your Internet browser. If you elect to block Cookies, you may not be able to access certain personalized sections of our Services such as Publisher reports. We also use log files and Cookies to improve the quality of our Site; to keep track of your login name, passwords, and pages you have visited on the Site; and to tailor content to your interests and to personalize the Site on your behalf.
(b) Information Sharing: We share Personal Information and Non-Personally Identifiable Information collected via the Site with other companies or individuals as follows:
¥ When they help us operate our business, such as with vendors that assist us in sending email, marketing and customer service.
¥ With third parties if we have a good faith belief that access, use, or disclosure of such information is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of MetroClick, its users or the public as required or permitted by law.
¥ With any of our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred.
¥ With third parties to whom you ask us to send Personal Information;
¥ In addition, we may aggregate your Non-Personally Identifiable Information with the Non-Personally-Identifiable Information of others and share that aggregated information with third parties without restriction.
(c) Forums: We make interactive forums (in the form of social media platforms) available on the Site. Any information that you post to these interactive forums or otherwise choose to make publicly available, including your Personal Information, may be disclosed and available to all users who have access to any interactive forum and is no longer private. Please be thoughtful about what you post and make publicly available through our interactive forums.
(d) Accessing and Controlling our use of your Personal Information: If you have provided Personal Information when registering for our Site, you may access and modify that information at any time by contacting MetroClick directly at sales@metroclick.com. While we would be sorry to see you go, you can delete your information at any time. Keep in mind, however, that even if you delete your account, we may retain your Personal Information in conformance with our data retention policy, under which we may retain such information to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and take other actions otherwise permitted by law. There may be residual Personal Information that remains within our databases, access logs, and other records. In addition, we are not responsible for updating or removing your Personal Information already disclosed to third parties who have been provided information as permitted by this Policy. You can opt out of receiving certain email communications from the Site by clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Site and Service related communications.

Privacy Practices for End Users who use the MetroClick Sharing Button on Publisher Websites
As part of the Service, we operate the MetroClick sharing platform, which makes sharing content on the web easy. If you are reading this policy, you are probably familiar with our buttons and menus that Publishers enable on their websites to allow you to share their content through email, social networking websites, blogs and more. When you, an End User use one of our buttons, menus and/or toolboxes that is enabled on one of our Publisher websites (an “MetroClick Platform”), we collect certain non-personally identifiable information automatically for use on our platform (the “MetroClick Platform”). We enable our Publishers to use this information via the Platform for analytics purposes, and we also use some of this information for online ad targeting as described below.

(a) The Information We Gather and How We Use It:
¥ Personal Information — We only collect Personal Information via an MetroClick website and/or interactive touch screen kiosk when an End User provides it to us. When you, an End User, send an email using an MetroClick Platform we use your email address, the email address of the person (or people) to whom you are sending the content and allow you the opportunity to write an accompanying message. We use this Personal Information only to send the email on your behalf and for no other purpose, and it is not merged or otherwise combined with any of the Non-Personally Identifiable Information that we collect. This Personal Information will be available to the people to whom you send or share content via the MetroClick Platform, so please be careful.
¥ Non-Personally Identifiable Information — We collect Non-Personally Identifiable Information via the MetroClick Platform for use on the MetroClick Platform. For example, when you visit a web page that contains one of our MetroClick Platforms, our server logs collect your Internet Protocol address, browser type, browser language, the date and time you visited that web page, and (if you came to a web page where an MetroClick Platform is enabled via a search engine such as Google), the web search that landed you on that web page. We also collect information regarding how often you share content with others using the MetroClick platform. We use this information to help us build commercially viable data segments (e.g., travel enthusiast, sports fan) for online ad targeting in order to help make the ads you see on many of the websites you visit more relevant to your interests, and for ad delivery and reporting purposes. For information regarding how we use this information to help deliver more relevant advertising please see the section below entitled “Targeted Advertising and Choices.” We also set Cookies and web beacons on web pages where our MetroClick Platforms are enabled, and allow our partners to set Cookies and web beacons that are subject to those partners’ privacy statements. We also use this information to customize the MetroClick Platform to your usage patterns. For example, if you share to Facebook, we make sure that Facebook icon is at the top of your MetroClick Platform menu.

(b) Information Sharing.
We generally don’t share Personal Information collected via the MetroClick Platform except as specifically directed by the End User in order to share a piece of content via email or via social networking platform. We share information collected via the MetroClick Platform with other companies or individuals as follows:
¥ We share Non-Personally Identifiable Information with partners and the website Publishers who have the MetroClick Platform enabled on their websites for analytics and other business purposes. For example, we provide our publishers with statistics on sharing trends, and the top content segments shared (e.g., A blog post analyzing a speech given by the President), so that Publishers can understand how End Users are sharing their content, as well as how much web traffic such sharing brings back to the Publisher’s site. Publishers may use this information to tailor content and advertising on individual publisher sites. Publishers can use filters to refine the data by domain, time period, geography, and other options.
¥ We share any information with third parties if we have a good faith belief that disclosure of such information is reasonably necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of MetroClick, its End Users or the public as required or permitted by law.
¥ We share information with our subsidiaries, joint ventures, or other companies under common control with us, in which case we will require them to honor this policy. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, we expect that any and all information that we have will be among the assets transferred.
¥ In addition, we may aggregate your Non-Personally Identifiable Information with the Non-Personally Identifiable Information of others and share that aggregated information with third parties without restriction.
(c) Targeted Advertising and Choices
We don’t use Personal Information to serve targeted advertising via the Platform. Most of our Services are available to End Users and Publishers at no cost. To support our Services, we license or otherwise provide the Non-Personally Identifiable Information we collect via many of the MetroClick Platforms enabled on Publisher websites and use that information via the Platform to deliver or enable the delivery of advertising that is customized to End User interests. We also set Cookies and web beacons on web pages where our MetroClick Platforms are enabled to help us with online ad targeting and to provide analytics to our website Publishers.
If you prefer that we do not collect Non-Personally Identifiable Information about your website visits for the purpose of delivering targeted advertising, you may opt out.
When you opt out, we will place an opt-out cookie on your computer. The opt-out cookie tells us not to use your information for delivering relevant online advertisements. Please note that if you block cookies, our opt-out process may not function properly. Please also note that if you delete, block, or otherwise restrict cookies, or if you use a different computer or Internet browser, you will need to renew your opt-out choice.
We also allow our partners to set cookies and web beacons via certain MetroClick Platforms. Some of them are also members of the Network Advertising Initiative (NAI). For more information, please visit the NAI website at Network Advertising Initiative.

(d) Health and Finance Data
We abide by the NAI and DAA Codes in the US, EU and Canada, which restrict the collection and use of health and finance data for online advertising. We do not use or share with third parties any health-related or finance-related data that we consider sensitive. We recognize that others may have differing views regarding which categories of health and finance data are sensitive.
The types of health information we utilize may be found by XXX. The types of finance information we utilize may be found by XXXX. While we do not consider any of these data categories to be sensitive, it is important to provide this transparency to help you have a better idea of what data might be collected by us, so that you can make informed decisions.
Privacy Practices for End Users Who Download and Use MetroClick Toolbars
In addition to the MetroClick Platforms that appear on Publisher websites, we offer toolbars (our “Toolbar”) that can be downloaded by End Users, installed as a plug-in on the End User’s browser and used to share content from virtually any website. We do not target advertising based upon information collected through any Toolbar. When an End User uses the Toolbar, we collect Non-Personally Identifiable Information about the End User’s usage of the Toolbar, including whether the End User downloads and installs the Toolbar, how and when the End User utilizes the Toolbar and when the End User uninstalls the Toolbar. We use this information to understand how the Toolbar is being used, and to help us ensure that our Toolbars are functioning properly. We also collect but do not store the keyword searches that each End User executes via the Toolbar. We collect the keyword searches in order to provide them to the search engine indicated in the Toolbar (e.g., Yahoo!), and such search engine’s use of the keywords is governed by its own privacy policy.

Information Security, Retention, and Data Integrity
We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems.

We restrict access to Personal Information to MetroClick employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances.

We retain Non-Personally Identifiable Information on the Platform for up to five years. Any search strings we collect via the MetroClick Platform are converted into Non-Personally Identifiable Information, and the raw search data is stored on our server logs for up to 90 days. Aggregate reports generated from such information may be kept longer.
MetroClick processes information in a way that is compatible with and relevant for the purpose for which it was collected.

Access
MetroClick will allow an individual access to their Personal Information to the extent it is available and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. If you have provided Personal Information when registering for our Site, you may access and modify that information at any time by visiting your account settings. If you’d like us to update, correct, delete, or deactivate any other Personal Information that you have provided to us, please send your request to us at sales@MetroClick.com and we will process your request within a reasonable period of time after receipt.

Children
We do not knowingly collect or maintain Personal Information from individuals who are under 13 years of age, and no part of our Site or Services are designed to attract people under the age of 13. Protecting the privacy of children is very important to us. If we obtain knowledge that a user is under the age of 13, we will take steps to remove that user’s Personal Information from our databases.

Links to Other Sites
Our Site and Services contain links to, and allow you to share content on, third party websites and services. The fact that we link to a website or service or allow you to share content on them is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. This privacy policy applies only as provided in the scope section above. Other websites and services follow different rules regarding the use or disclosure of the personal information. We encourage you to read the privacy policies or statements of the other websites you visit.

International Users
The Site and Services are hosted in the United States. If you access the Site or Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Site or Services, you are transferring your Personal Information to the United States and you consent to that transfer. Additionally, you understand that your Personal Information may be processed in countries (including the United States) where laws regarding processing Personal Information may be less stringent than in your country.

Enforcement, Questions, and Complaints
MetroClick regularly reviews its compliance with this Privacy Policy. In compliance with the U.S.-EU and U.S-Swiss Safe Harbor Principles, MetroClick commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union and Swiss citizens and others with inquiries or complaints regarding this privacy policy should first contact MetroClick by emailing us at sales@metroclick.com or writing to us at:

Privacy Office
c/o MetroClick
121 Varick Street
3rd Floor
New York, NY 10013
USA

MetroClick has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if the Privacy Officer at MetroClick does not satisfactorily address your complaint, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

Changes to this Privacy Policy
Please note that this Privacy Policy may change from time to time. If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this Site or by writing to us at the address set forth above.

Last Updated: July 28, 2018